There are some important things you need to consider when applying for a Part 102 certificate.
3 Nov 2023 update: The Part 102 Certification team has released some additional information related to the XAG P100 Pro aircraft. Please read this in the dropdown below.
The Civil Aviation Authority’s Part 102 Certification team has recently assessed the XAG P100 Pro Agricultural Aircraft for use in New Zealand. In doing so it became apparent that there are some reasonably significant changes in design between the XAG P100 and the XAG P100 Pro; including folding rotor arms and teeter rotor assemblies. An industry specialist inspection report suggested that particular attention should be given to the differences these new elements introduce, especially for those operators who have been operating the XAG P100.
It is common practice for the Part 102 team to issue a 'series' approval for certain aircraft types on the Part 102 certificate Operations Specifications document. This has been the case for the XAG P100 series to date. We have been able to consider this because the series of aircraft have generally remained very similar in form and function. More significant changes to an aircraft’s airframe design has tended to result in the manufacturer giving the new aircraft a completely new model name. However in this case, XAG has introduced these pronounced design changes but kept the P100 name.
Because of the differences between the original XAG P100 and their new P100 Pro, the Part 102 Certification team is NOT prepared to approve the XAG P100 Pro as part of an ‘XAG P100 series’ without a small but important amendment to the operational procedures. This change is needed to ensure appropriate attention to the design changes with the XAG P100 Pro have been included. The Part 102 Team will amend the wording on the Operations Specification documents going forward to reflect this change.
We expect any operator wanting to add the XAG P100 or XAG P100 Pro to be aware of this situation and to amend their exposition as outlined below.
The following safety mitigations have been recommended by an industry specialist and accepted by CAA as expected (best) practice for the XAG P100 Pro aircraft:
Thank you for your consideration. Any questions can be emailed to firstname.lastname@example.org.
Before getting started, make sure you've read the information on Intro to Part 102 certification for unmanned aircraft.
Here are some helpful tips to help you with the application process.
Read the application form [DOCX 68 KB] carefully and fill out each section. Make sure to sign where you need to (this is often missed by applicants).
Reading Advisory Circular (AC) 102-1 Unmanned Aircraft - Operator Certification will provide additional information about what is required for Part 102 certification.
If your exposition writer fills out the form for you, you need to ensure that it’s what you expect and you understand what you're applying for - before signing and submitting it. Your manual content and application form requests need to match.
Make sure your fit and proper person (FPP) questionnaire (CAA24FPP [PDF 1.8 MB]) is completed in full. Also, check that your proof of identification and address for service are signed by your nominated referee.
Note: If you're applying for a renewal, you only need to supply a new declaration (24FPPDec [PDF 1.3 MB]) and updated CV (this is as long as the you've completed a full FPP within the previous five years).
Before submitting your application, double-check that you have included the matrix and manuals that you may need to include.
When you apply, your documentation is checked for completeness and that all initially required documents have been provided; not their quality. So, ensuring your documentation is ready for assessment when we review your application is vital to save you and us as much time as possible. Keep in mind that assessment of manuals incurs an hourly fee, so, the more complete your information, the lower costs you're likely to incur.
CAA is developing a number of Sample Expositions that will illustrate the level of detail you will need to cover for a particular type of operation and organisational complexity. Check out our Sample Expositions section to see if any fit your circumstances.
If your operation is beyond the scope of our Sample Expositions, be aware that without any prior aviation industry and/or technical writing experience, your exposition may require significant corrections or could be rejected if not complete. Time spent by CAA inspectors on your application is chargeable, so it can mean your assessment becomes more costly. Using OneReg (see below) may help you avoid making errors when writing your exposition.
If you write your own exposition, even if based on a CAA Sample Exposition, here are some extra tips:
OneReg(external link) is an independent company that has developed an exposition creation and management portal which has been customised for Part 102 applications with the aim of making it easier for participants to meet their regulatory requirements. This includes making submissions or applications to participating regulators. In a non-exclusive arrangement, the Authority will allow participants to submit their expositions via OneReg if they choose to do so. There is extra cost when you use this service but it may reduce the time spent (and cost) assessing your application. Using OneReg doesn’t give you preferential placement in the application queue.
If you hire an exposition writer, it's more likely to be a smoother assessment process, however each manual must be tailored to reflect your organisation's specific way of operating, so some changes may still be required during the assessment process.
When working with an exposition writer, you're not required to adapt your application to their standard exposition template. You need to make it clear to the writer about the type of operations you'll be conducting, and have the writer modify the exposition to reflect exactly how you'll be operating. We're seeing some applications where the writer is adapting applications to fit their standard exposition version; whereas the exposition writer should be altering each manual to fit the specific circumstances for each applicant.
Remember that if you have someone else write your exposition, you still need to understand it completely - this is very important.
In this section you'll find sample expositions and explanatory notes that describe the use cases that can be used under the sample expositions.
102SE001 Operations Manual [DOCX 172 KB] (sample exposition for real estate type operations using commercial off the shelf UA)
102SE001 Explanatory Note [PDF 200 KB] (provides more detail of the type of operations that can be used under this sample exposition)
Before you purchase high value aircraft or equipment, be aware that if they are new to New Zealand (e.g. unique, first of type, or first of use), more assessment will be required. We cannot say if we'll accept the craft(s) for the use you intend until we assess your application.
Also, keep in mind that as we're experiencing a high number of applications, there could be several months delay. So please take this into consideration before committing to purchasing or financing aircraft and equipment.
The Prime Person in your organisation must be able to demonstrate they have sufficient knowledge and understanding of their exposition and the rules. You'll be interviewed by an inspector to determine whether or not you have the required knowledge and experience to hold this important role. A Part 102 training course with an approved training provider can assist. Consider the timing of that training so it can still be fresh in your mind. Also consider that most training organisations offer tailored training on request.
The CAA Good Aviation Practice booklet How to be a senior person [PDF 787 KB] will assist further.
If what you're applying to do is new to New Zealand, unique, first of type, or first of use case, there will be more work to do. As the scale, complexity, air, or ground risk increases so too does the assessment process, the requirements on the applicant, and the time and cost involved.
CAA is in the early stages of setting up an Emerging Technology Programme to help guide applicants with these sorts of applications. The aim is to ensure that information sent for Certification is sufficiently mature and that applicants have a firm understanding of how the aviation system and approval processes work. Having a firm idea of your trialling and development timelines, goals, milestones and necessary enablers will greatly assist CAA in providing this guidance. If you think that your application may benefit from such engagement, please mention this at your first interaction with the 102 Cert Team.
Not only is your manual assessed, but the combination of craft(s) you intend to use, where, for what purpose and when you intend to use them. That's why no two applications are the same.
If you're using an exposition writer, they'll likely provide some guidance as to the complexity of what you're applying for.
You may have heard that the CAA asks for a JARUS SORA (specific operations risk assessment) for complex operations. This is the case for some very complex applications - like BVLOS and large drones. At this time it is by request once we start on your application, so you don’t need to do it unless you're asked for it.
If you have been told by CAA that you need to complete a formal risk assessment with your application and you are going to use JARUS SORA, then this spreadsheet is designed to assist you through the JARUS SORA steps. The spreadsheet is an additional tool, it does not replace creating your JARUS SORA assessment document (sometimes called a SORA Safety Portfolio) and it should be provided alongside your SORA document(s) if you use it. There are instructions for the spreadsheet on the first tab within it. This tool is designed to assist the applicant to be clear on their intentions and claims at each SORA step and to give the applicant a place to capture references to where in their documentation each SORA requirement is evidenced. This assists the applicant to ensure they have provided all required evidence in their SORA document. This also greatly assists the CAA assessor(s) to navigate your SORA document(s).
You must supply all documents at the time of application, but due to delays in your application being processed, we understand that some things can change during that time. This could even just be your contact information - do let the team know if your contact details change while you're waiting.
We'll contact you when we start on your assessment. One question we'll ask is "has anything changed since you submitted your application?" If something has changed, we'll work with you to incorporate those changes before assessing what you've provided.
So, purchasing the new model craft, or getting two craft instead of one, having a different pilot, etc, are all ok, and will not put you back in the application queue.
Once we start assessing your application, please be ready to take the time to provide information promptly when asked, and work with the team.
Stopping and starting the assessment can lead to additional time and therefore additional cost.
If you aren't ready to proceed when your application is assigned to an inspector for assessment, please let us know, so your application can be placed on hold without it going to the back of the queue. We'd much prefer not to start your assessment, then have to stop part-way through because you have other commitments.